2026-VIL-23-AAR
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SGST Advance Ruling Authority

GST – Andhra Pradesh AAR - Classification and applicable GST rate on Paddle Wheel Aerator and its Parts - Applicant is engaged in manufacturing and supply of Paddle Wheel Aerators and their parts used exclusively in aquaculture ponds for shrimp, fish, crab, and related farming activities - Whether the Paddle Wheel Aerator is correctly classified under HSN 8436 80 90 – HELD - The Paddle Wheel Aerator is correctly classifiable under HSN 84798999 as "Machines and mechanical appliances having individual functions, not specified or included elsewhere in this Chapter", as it aligns with the mechanical function of water agitation and oxygen transfer, rather than being reclassified under HSN 8436 which targets land-based agricultural, horticultural, or poultry machinery - Paddle wheel aerators warrant continued classification under HSN 84798999 at the applicable GST rate rather than a shift to HSN 84368090 post issuance of Notification No. 9/2025-Central Tax (Rate), dated 17th September 2025 - The correct GST rate applicable on the Paddle Wheel Aerator is 18% - Ordered accordingly - Whether the exclusive parts of the Paddle Wheel Aerator are correctly classifiable under HSN 8436 99 90 at 5% GST – HELD – The parts like Float Assembly, Paddle Wheel Impellers, Frame and Rods, Power train, and Protective Dome Cover, which are designed and used exclusively as parts of the Paddle Wheel Aerator, classify under their material/function (e.g., 8479 parts if tied to 8479 machines), not automatically with a proposed 8436 heading unproven for the complete unit. Exclusive use requires the principal machine's classification, preserving 18% where 8436 does not apply.
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